Proposed Rule2026-06940
Air Plan Approval; Ohio; Source-Specific Non-CTG RACT for Ohio
Primary source
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Published
April 10, 2026
Issuing agencies
Environmental Protection Agency
Abstract
The Environmental Protection Agency (EPA) is proposing to approve source-specific State Implementation Plan (SIP) revisions submitted by Ohio. These revisions address major source volatile organic compound (VOC) and nitrogen oxide (NO<INF>X</INF>) reasonably available control technology (RACT) requirements for the Cleveland, OH Moderate nonattainment area (Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit counties) under the 2015 ozone National Ambient Air Quality Standard ("NAAQS" or "standard"). The affected facilities include Lubrizol, Henkel, and Cleveland-Cliffs Cleveland Works. If this action is finalized as proposed, the Cleveland nonattainment area will have fully satisfied its moderate RACT requirements under the CAA with respect to the 2015 ozone standard.
Full Text
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<title>Federal Register, Volume 91 Issue 69 (Friday, April 10, 2026)</title>
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[Federal Register Volume 91, Number 69 (Friday, April 10, 2026)]
[Proposed Rules]
[Pages 18349-18355]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-06940]
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 52
[EPA-R05-OAR-2025-0237; FRL-13273-01-R5]
Air Plan Approval; Ohio; Source-Specific Non-CTG RACT for Ohio
AGENCY: Environmental Protection Agency (EPA).
ACTION: Proposed rule.
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SUMMARY: The Environmental Protection Agency (EPA) is proposing to
approve source-specific State Implementation Plan (SIP) revisions
submitted by Ohio. These revisions address major source volatile
organic compound (VOC) and nitrogen oxide (NO<INF>X</INF>) reasonably
available control technology (RACT) requirements for the Cleveland, OH
Moderate nonattainment area (Cuyahoga, Geauga, Lake, Lorain, Medina,
Portage, and Summit counties) under the 2015 ozone National Ambient Air
Quality Standard (``NAAQS'' or ``standard''). The affected facilities
include Lubrizol, Henkel, and Cleveland-Cliffs Cleveland Works. If this
action is finalized as proposed, the Cleveland nonattainment area will
have fully satisfied its moderate RACT requirements under the CAA with
respect to the 2015 ozone standard.
DATES: Comments must be received on or before May 11, 2026.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-R05-
OAR-2025-0237 at <a href="https://www.regulations.gov">https://www.regulations.gov</a>, or via email to
<a href="/cdn-cgi/l/email-protection#19786b6b78376a786b7871597c6978377e766f"><span class="__cf_email__" data-cfemail="4c2d3e3e2d623f2d3e2d240c293c2d622b233a">[email protected]</span></a>. For comments submitted at <a href="http://Regulations.gov">Regulations.gov</a>, follow
the online instructions for submitting comments. Once submitted,
comments cannot be edited or removed from the docket. The EPA may
publish any comment received to its public docket. Do not submit
electronically any information you consider to be Confidential Business
Information (CBI), Proprietary Business Information (PBI), or other
information whose disclosure is restricted by statute. Multimedia
submissions (audio, video, etc.) must be accompanied by a written
comment. The written comment is considered the official comment and
should include discussion of all points you wish to make. The EPA will
generally not consider comments or comment contents located outside of
the primary submission (i.e. on the web, cloud, or other file sharing
system). For additional submission methods, please contact the person
identified in the FOR FURTHER INFORMATION CONTACT section. For the full
EPA public comment policy, information about CBI, PBI, or multimedia
submissions, and general guidance on making effective comments, please
visit <a href="https://www.epa.gov/dockets/commenting-epa-dockets">https://www.epa.gov/dockets/commenting-epa-dockets</a>.
FOR FURTHER INFORMATION CONTACT: Katie Caskey, Air and Radiation
Division (AR18J), Environmental Protection Agency, Region 5, 77 West
Jackson Boulevard, Chicago, Illinois 60604, telephone number: (312)
353-3490, email address: <a href="/cdn-cgi/l/email-protection#670406140c021e490c06130f0b0202092702170649000811"><span class="__cf_email__" data-cfemail="5f3c3e2c343a2671343e2b37333a3a311f3a2f3e71383029">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION: Throughout this document whenever ``we,''
``us,'' or ``our'' is used, we mean the EPA.
Table of Contents
I. RACT Requirements
II. History of the Cleveland Nonattainment Area Under the 2015 Ozone
NAAQS
III. History of Ohio's VOC and NO<INF>X</INF> RACT Regulations
IV. What is the EPA proposing?
V. Lubrizol
VI. Henkel
VII. Cleveland-Cliffs Cleveland Works--NO<INF>X</INF> RACT
VIII. Cleveland-Cliffs Cleveland Works--VOC RACT
IX. What action is the EPA taking?
X. Incorporation by Reference
XI. Statutory and Executive Order Reviews
I. RACT Requirements
VOCs and NO<INF>X</INF> contribute to the production of ground-
level ozone, or smog, which harms human health and the environment. The
EPA has consistently defined RACT as the lowest emission limit that a
particular source is capable of meeting by the application of control
technology that is reasonably available considering technological and
economic feasibility.\1\
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\1\ See Memorandum from Roger Strelow, Assistant Administrator
for Air and Waste Management, U.S. EPA, to Regional Administrators,
U.S. EPA, ``Guidance for Determining Acceptability of SIP
Regulations in Non-Attainment Areas'' (Dec. 9, 1976); see also 44 FR
53761, 53762 (September 17, 1979).
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Sections 182(b)(2) and 182(f) of the Clean Air Act (CAA), when
taken together, require States to implement RACT for VOC and
NO<INF>X</INF> in ozone nonattainment areas classified as Moderate and
higher. Specifically, these areas are required to implement RACT for
all sources covered by a Control Techniques Guideline (CTG) and all
other major stationary sources of VOCs and NO<INF>X</INF> in the
area.\2\ For the purposes of RACT in Moderate ozone nonattainment
areas, major sources of VOCs and NO<INF>X</INF> are those that are not
covered by CTGs and have the potential to emit (PTE) at least 100 tons
per year (tpy).
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\2\ CTGs provide recommendations to inform State, local, and
Tribal air agencies as to what constitutes RACT for categories of
VOC sources.
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To address non-CTG RACT requirements, Ohio adopted Ohio
Administrative Code (OAC) rules 3745-21-11 and 3745-110-03(J), which
require major sources of VOCs and NO<INF>X</INF> that are not covered
by a CTG to submit detailed source-specific RACT studies analyzing the
technological and economic feasibility of available control measures.
Ohio evaluated the information provided in the required studies, made a
RACT determination for each major source, and submitted the RACT
determinations to the EPA for approval and incorporation into the Ohio
SIP.
[[Page 18350]]
II. History of the Cleveland Nonattainment Area Under the 2015 Ozone
NAAQS
Effective August 3, 2018, the EPA designated the Cleveland
nonattainment area as a Marginal nonattainment area for the 2015 ozone
NAAQS (``Cleveland nonattainment area'').\3\ The Cleveland
nonattainment area consists of Cuyahoga, Geauga, Lake, Lorain, Medina,
Portage, and Summit counties. On October 7, 2022, pursuant to section
181(b)(2) of the CAA, the EPA determined that the Cleveland
nonattainment area failed to attain the 2015 ozone NAAQS by the August
3, 2021, Marginal area attainment deadline and thus proposed to
reclassify the area from Marginal to Moderate nonattainment.\4\ In that
action, the EPA established January 1, 2023, as the due date for the
State to submit all Moderate area nonattainment plan SIP requirements
applicable to newly reclassified areas. Since the Cleveland
nonattainment area was reclassified to Moderate, the area was required
to meet the RACT requirements discussed above at 100 tpy. On December
17, 2024, the EPA determined that the Cleveland nonattainment area
failed to attain the 2015 ozone NAAQS by August 3, 2024, Moderate area
attainment deadline and thus reclassified the area from Moderate to
Serious nonattainment. The new Serious RACT requirement was due on
January 1, 2026, but this action addresses Moderate RACT requirements
only.\5\
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\3\ 83 FR 25776 (June 4, 2018).
\4\ 87 FR 60897 (October 7, 2022).
\5\ 89 FR 101901 (December 17, 2024).
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III. History of Ohio's VOC and NOX RACT Regulations
Ohio has adopted regulations to address the NO<INF>X</INF> and VOC
RACT requirements that apply to Moderate ozone nonattainment areas. The
NO<INF>X</INF> RACT rules, in OAC Chapter 3745-110, effective March 25,
2022, apply to existing boilers, stationary combustion turbines,
stationary internal combustion engines, reheat furnaces, and other
sources at facilities that have an uncontrolled potential to emit 100
tpy or more of NO<INF>X</INF>. These rules apply to sources located in
the Cleveland nonattainment area.
Similarly, the VOC RACT rules, in OAC Chapter 3745-21, effective
March 27, 2022, apply to various VOC source categories in the Cleveland
nonattainment area. These rules cover both CTG source categories and
non-CTG major sources with an uncontrolled potential to emit 100 tpy or
more of VOCs.
Ohio EPA submitted OAC Rules 3745-21-11 and 3745-110-03(J) to the
EPA for approval and inclusion in the SIP on March 31, 2022. These
rules require major non-CTG VOC and NO<INF>X</INF> sources located in
ozone nonattainment areas classified as Moderate or higher to submit
RACT studies to Ohio within one year of the rule's effective date.
These RACT studies contain information on the technical and economic
feasibility of VOC and NO<INF>X</INF> emission control measures to
inform Ohio's RACT determinations for each major source.
On January 20, 2026 (91 FR 2308), the EPA approved portions of OAC
Chapters 3745-21 and 3745-110 as satisfying certain moderate VOC RACT
and NO<INF>X</INF> RACT requirements for the Cleveland nonattainment
area. In the same action, the EPA also approved OAC 3745-21-11 and
3745-110-03(J) as SIP strengthening measures for the Cleveland area
designated nonattainment under the 2015 ozone standard.
On February 27, 2026 (91 FR 9771), the EPA proposed to approve
source-specific moderate non-CTG RACT for certain facilities in the
Cleveland nonattainment area under the 2015 ozone standard subject to
OAC 3745-21-11 and 3745-110-03(J). The EPA has not yet finalized that
proposed action. This action addresses the remaining non-CTG major
source RACT facilities subject to OAC 3745-21-11 and 3745-110-03(J) in
the Cleveland nonattainment area.
IV. What is the EPA proposing?
The EPA is proposing to approve the following RACT determinations
submitted by Ohio for major sources of VOCs and NO<INF>X</INF> in the
Cleveland nonattainment area as meeting RACT requirements.
V. Lubrizol
Lubrizol operates a chemical manufacturing facility located in
Painesville, Ohio, within the Cleveland nonattainment area. The
facility is subject to source-specific RACT requirements under OAC
3745-21-09(LL) for its process reactor systems. As a major non-CTG VOC
source, Lubrizol must also submit an updated source-specific RACT study
under OAC 3745-21-11. Ohio submitted a VOC RACT determination based on
this study to the EPA on October 8, 2025. Lubrizol manufactures
specialty chemical products, including additive systems for lubricating
oils used in gasoline and diesel engines, automatic transmissions, gear
drives, marine engines, tractors, and metalworking. The primary VOC
emission sources are process reactor systems, drum/tote filling lines,
and product loading racks.
The EPA approved OAC 3745-21-09(LL) into the Ohio SIP to address
non-CTG VOC RACT for the 1-hour ozone standard on April 25, 1996 (61 FR
18255). The rule requires all reactor process vent streams to be routed
to an enclosed combustion device that achieves at least 98 percent VOC
destruction (or 20 parts per million by volume(ppmv) outlet
concentration) or provides at least 0.75 seconds of residence time at
1600 [deg]F. Lubrizol meets and exceeds these requirements. Reactor
vent emissions are controlled by two redundant thermal oxidizers that
achieve over 99.9 percent VOC destruction efficiency. Continuous
temperature monitoring ensures proper combustion and consistent
performance between tests. Lubrizol reviewed the EPA's RACT/BACT/LAER
Clearinghouse (RBLC) for due diligence purposes and found that that
BACT for process vents in the chemical manufacturing industry typically
requires add-on controls achieving 98 percent destruction efficiency.
The existing 98 percent control is more stringent than the non-CTC RACT
catch-all provisions in other Region 5 State rules, including Illinois
and Indiana (which require at least an 81 percent reduction in VOC
emissions). Since Lubrizol achieves greater than BACT-level control and
is more stringent than the non-CTG RACT catch-all rules described
above, Ohio determined that continued compliance with OAC 3745-21-
09(LL) satisfies RACT for these emission units.\6\ The EPA is proposing
to approve Ohio's RACT determination that these controls implement
RACT.
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\6\ Prevention of Significant Deterioration (PSD) permits are
required for new major sources or a major source making a major
modification in areas that meet the NAAQS. PSD permits require the
installation of Best Available Control Technology (BACT). BACT is an
emissions limitation which is based on the maximum degree of control
that can be achieved. It is a case-by-case decision that considers
energy, environmental, and economic impact. BACT can be add-on
control equipment or modification of the production processes or
methods. The RACT/BACT/LAER Clearinghouse (RBLC) database contains
information on what has been required as BACT in air permits.
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Emission unit P132 includes four drum lines and one tote line. VOC
emissions from these operations are vented to the same thermal
oxidizers used for the reactor vents described in the prior paragraph,
which achieve over 99.9 percent destruction efficiency. The facility is
currently required to implement submerged filling and venting to a
thermal oxidizer capable of at least 98 percent destruction
[[Page 18351]]
efficiency. These practices meet or exceed recent BACT determinations
for similar filling operations, which typically require submerged
filling and add-on controls achieving at least 98 percent VOC
reduction. Therefore, Ohio determined that submerged filling combined
with thermal oxidation (>=98 percent efficiency) constitutes RACT for
these operations. The EPA proposes to approve Ohio's assessment that
these controls implement RACT.
Lubrizol operates multiple product loading racks, many equipped
with thermal oxidizers or carbon adsorption systems. Actual VOC
emissions from these units ranged from 0.01 to 0.88 tpy during 2019-
2021. Based on the EPA's estimate of the cost of additional control
technologies, which is well over $30,000 per ton of VOC removed, the
EPA is proposing to find that additional controls would not be
economically reasonable. To minimize emissions, Lubrizol implements
work practices including ensuring complete drainage of loading arms
before disconnection and preventing liquid drainage when not in use.
Many loading racks are also subject to VOC limits under Best Achievable
Technology (BAT).\7\ Ohio determined that RACT for these operations
consists of existing controls, emission limits, and work practices
listed in Table 3-2 of Lubrizol's RACT submittal (included in the
docket). Ohio included these requirements in a construction permit and
is requesting that the EPA incorporate these provisions of the permit
into the SIP. The EPA proposes to approve Ohio's RACT determination
that these controls implement RACT.
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\7\ BAT is defined in OAC 3745-31-01(B)(6) as ``any combination
of work practices, raw material specifications, throughput
limitations, source design characteristics, an evaluation of the
annualized cost per ton of air pollutant removed, and air pollution
control devices that have been previously demonstrated to the
director of environmental protection to operate satisfactorily in
this state or other states with similar air quality on substantially
similar air pollution sources.''
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In sum, the EPA is proposing to approve Ohio's RACT determination
for Lubrizol as adequately implementing RACT, which includes the
following measures summarized above and in Table 3-3 of the docket:
continued compliance with site-specific RACT under OAC 3745-21-09(LL)
for all process reactor vents; use of submerged filling and venting to
a thermal oxidizer achieving greater than 98 percent VOC control
efficiency for the drum/tote filling operations; and implementation of
existing controls, emission limits, and work practices for the loading
racks as specified in the permit sections listed below. Given the
already low emissions at Lubrizol (.01 to .88 tpy of VOC) and the EPA's
cost estimate described above, additional controls would be
economically unreasonable.
The EPA proposes to incorporate by reference the above RACT
requirements from permit number P0138405 (effective date: October 1,
2025), specifically sections (B)(2)-(B)(5), (C)(1)(b)(1)(b),
(C)(1)(b)(2)(a), (C)(1)(d)(1), (C)(1)(e)(1), and (C)(1)(f)(2).
VI. Henkel
Henkel US Operations Corporation operates an adhesives and sealants
manufacturing facility in Mentor, Ohio, within the Cleveland ozone
nonattainment area. The facility is a major source of non-CTG VOC
emissions and must submit a source-specific RACT study under OAC 3745-
21-11. Ohio submitted this VOC RACT determination to the EPA on
November 25, 2025.
The facility produces adhesives and sealants by blending organic
solvents and inert fillers in batch mixers, which are the primary
sources of VOC emissions. VOC emissions are controlled with condensers
that circulate a chilled water/propylene glycol mixture through coiled
tubes, cooling vent gases and condensing a portion of the VOC vapors.
To fulfill requirements of the National Emissions Standards for
Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating
Manufacturing (MCM), Henkel submitted to Ohio EPA a condenser design
evaluation to demonstrate MACT compliance, establishing maximum outlet
gas temperatures.\8\ Using the same methodology, Henkel later submitted
a design evaluation to demonstrate 85 percent VOC removal efficiency
under OAC 3745-21-07(M), resulting in lower outlet temperature limits.
OAC 3745-21-07(M) contains Ohio's facility-specific VOC control
requirements for emissions of organic materials from stationary
sources.
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\8\ 40 CFR part 63 subpart HHHHH-NESHAP: Miscellaneous Coating
Manufacturing requires this condenser design evaluation per 40 CFR
63.1257(d) for the initial compliance demonstration of maximum
achievable control technology (MACT) on the existing process vessels
at this plant.
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Achieving removal efficiencies above 85 percent would require
reducing condenser outlet temperatures further-either by lowering
coolant temperatures or increasing condenser surface area. However, the
chilled water system already operates near the freezing point, and past
attempts to reduce temperatures have caused ice formation and vent
blockages. A two-stage condenser system or larger condensers could
mitigate this issue but, would require significant equipment
replacement and reconfiguration, with minimal additional VOC reduction,
so would be economically unreasonable. Further, 85 percent reduction is
higher than the non-CTG RACT catch call rules in other States in Region
5, including Illinois and Indiana, which require 81 percent reduction
in VOC emissions at a minimum.
Henkel also evaluated alternative add-on controls, including
incineration, carbon adsorption, and biofiltration. Biofiltration is
technically infeasible because the facility's predominant VOCs are
water-insoluble. Incineration and carbon adsorption are technically
feasible, but not cost-effective: incineration would cost between
$32,109-$43,841 per ton of VOC removed, and carbon adsorption would
cost $29,482 per ton.
These analyses show that add-on controls are either technically
infeasible or economically unreasonable. The existing condensers
already achieve 85 percent VOC reduction, and the facility has already
substantially lowered its VOC emissions by shifting production toward
low- or no-VOC materials.
Based on Henkel's analysis, Ohio EPA concludes that the facility's
current practices-use of low-VOC materials and condenser systems
achieving 85 percent control-are RACT for this source. Ohio included
these requirements in a construction permit and is requesting that the
EPA incorporate these provisions of the permit into the SIP.
The EPA proposes to approve Ohio's assessment that these controls
implement RACT and to incorporate by reference the above RACT
requirements from permit number P0138691 (effective date: November 18,
2025), specifically sections B.4, C.1.b)1.g, C.1.c)2,C.1.d)5,
C.1.e)7,C.1.f)2, C.2.b)1.f, C.2.c)2, C.2.d)6, C.2.e)7, C.2.f)2,
C.3.b)1.g, C.3.c)2,C.3.d)5, C.3.e)7, C.3.f)2, C.4.b)1.g,
C.4.c)4,C.4.d)5, C.4.e)6,C.4.f)2, C.5.b)1.j,C.5.c)3, C.5.d)6, C.5.e)9,
C.5.f)2, C.6.b)1.d, C.6.c)2, C.6.d)2, C.6.e)4, C.6.f)3, C.7.b)1.d,
C.7.c)2, C.7.d)2,C.7.e)4, and C.7.f)3.
VII. Cleveland-Cliffs Cleveland Works--NOX RACT
Cleveland-Cliffs Cleveland Works LLC is an integrated steelmaking
plant in the Cleveland nonattainment area. Because the facility is a
major source of NO<INF>X</INF> with a PTE greater than 100 tpy, it is
subject to site-specific NO<INF>X</INF> RACT under OAC 3745-110-03(J).
Ohio submitted this NO<INF>X</INF> RACT determination to the EPA on
November 20, 2025.
The facility emits NO<INF>X</INF> from numerous sources, including
boilers, reheat furnaces, batch annealing furnaces, a continuous
annealing line,
[[Page 18352]]
blast furnaces, basic oxygen furnaces, and ladle preheaters. The
facility operates under title V permit No. P0129660, effective March 9,
2021.
Boilers B001 through B007 are already subject to the NO<INF>X</INF>
RACT limits in OAC 3745-110-03(C) and (D)-0.08 pounds per million
British thermal units (lb/MMBtu) for gas-fired boilers, 0.2 lb/MMBtu
for residual-oil-fired boilers, and 0.3 lb/MMBtu for coal-fired
boilers-and are therefore already implementing RACT in accordance with
these federally approved provisions. The EPA has previously approved
OAC 3745-110-03(C) and (D) as satisfying moderate NO<INF>X</INF> RACT
for the Cleveland nonattainment area (January 20, 2026, 91 FR 2308).
A. Reheat Furnaces
Cleveland-Cliffs operates three natural-gas-fired reheat furnaces:
Reheat Furnaces #1 (P046), #2 (P047), and #3 (P048)-each rated at 630
MMBtu/hr. Cleveland-Cliffs evaluated selective catalytic reduction
(SCR), selective noncatalytic reduction (SNCR), and upgraded low-
NO<INF>X</INF> burners (LNBs) as potential NO<INF>X</INF> control
options.
Cleveland-Cliffs found SCR technically infeasible. The batch-type
furnace operation involves frequent door openings and unstable exhaust
temperatures, which prevent the consistent temperature control required
for effective SCR catalyst performance.
Cleveland-Cliffs also determined that SNCR is technically
infeasible. Exhaust temperatures are too low for effective
NO<INF>X</INF> reduction, and reheating the flue gas to reach the
required temperature would significantly increase fuel use and produce
additional NO<INF>X</INF>.
The reheat furnaces currently use LNBs. Cleveland-Cliffs evaluated
replacing the current burners with newer LNB models capable of
achieving 0.074 lb/MMBtu (compared to the current 0.35 lb/MMBtu limit).
However, the high cost--$14,631 to $29,400 per ton of NO<INF>X</INF>
removed--renders this option economically unreasonable.
Ohio determined that putting on additional controls for the reheat
furnaces is technically infeasible and economically unreasonable.
However, Ohio requires the source to submit an updated RACT study if
the NO<INF>X</INF> emissions ever exceed 348.3 tpy per rolling 12-month
period for each reheat furnace. If emissions are higher than 348.3 tpy
for a 12-month period, then the cost of the available control
technologies per ton of NO<INF>X</INF> removed may become economically
reasonable.
This emission level was based on the highest maximum actual
emissions among the previous three years from the effective date of OAC
rule 3745-110-03. If a unit exceeds this level during any 12-month
rolling period, the facility must submit a new RACT analysis to Ohio
within one year. The EPA is proposing to approve Ohio's RACT
determination for units P046-P048 and the requirement that the source
submit an updated RACT study to Ohio if the units exceed the emission
level of 348.3 tpy of NO<INF>X</INF>.
B. Batch Annealing Furnaces
At Cleveland Works, there are currently 77 operational and nine
spare batch annealing furnaces at the North Annealing (P049) and South
Annealing (P050) sections. Batch annealing emissions exhaust through
multiple indoor stacks, and the system lacks a common stack suitable
for post-combustion controls. Therefore, SCR and SNCR are technically
infeasible for batch annealing operations.
The batch annealing furnaces have existing LNBs with inherently low
NO<INF>X</INF> emissions of 1.2 tpy each for units P049 and P050, as
demonstrated by the current NO<INF>X</INF> emission limit of 0.10 lb/
MMBtu, which is consistent with the most recent BACT determination in
the EPA's RBLC database. Due to the already low NO<INF>X</INF> emission
levels, installing newer model LNBs to achieve only marginal additional
NO<INF>X</INF> reductions from the batch annealing furnaces would not
be economically reasonable. Ohio determined that RACT for batch
annealing sections P049 and P050 is continued use of the existing LNBs
and continued compliance with the 0.10 lb/MMBtu limit.
C. Hot Dip Galvanizing Line
The Hot Dip Galvanizing Line (HDGL) includes a 159.17 MMBtu/hr
continuous annealing furnace. SCR and SNCR are technically infeasible
with the current stack configuration. Its current stack configuration
poses significant challenges for installing post-combustion controls.
Two exhaust ducts discharge into a common stack inside the building.
Installing SCR or SNCR would require removing the existing stack,
consolidating the ducts into a single duct, and routing the system to a
new external stack, which is economically unreasonable. Cleveland-
Cliffs therefore determined that SCR and SNCR are both economically
unreasonable and technically infeasible.
The furnace currently uses LNBs with expected NO<INF>X</INF>
loadings of 0.27 to 0.30 lb/MMBtu. Cleveland-Cliffs evaluated the cost-
effectiveness of replacing the existing burners with newer LNB models
and found it would cost $31,937 to $37,998 per ton of NO<INF>X</INF>
removed, which the State determined is economically unreasonable. Ohio
determined that RACT for the HDGL Annealing Furnace (Unit P071)
consists of continued use of the existing LNBs and compliance with the
0.23 lb/MMBtu NO<INF>X</INF> limit. The EPA proposes to approve Ohio's
RACT determination that these controls implement RACT.
D. Blast Furnaces
Cleveland-Cliffs operates two blast furnaces (P903 and P904)
subject to this RACT review. Both units burn blast furnace gas (BFG),
which has a low heating value and limits combustion temperature,
resulting in inherently low NO<INF>X</INF> emissions and minimal
potential for further reduction. NO<INF>X</INF> emissions at the blast
furnaces are from the stoves, the cast house, and the flare.
In the cast house, natural gas is used for flame suppression during
casting, and NO<INF>X</INF> forms when the gas exits pipe ends and
ignites. Because these emissions are fugitive and lack a stack, SCR and
SNCR are technically infeasible. The flare burns excess furnace gas and
is an open system without a stack, making SCR and SNCR infeasible there
as well.
For the stoves, SCR installation is technically infeasible due to
exhaust temperatures (500 [deg]F) below the 600 to 700 [deg]F operating
range, the need to reheat large gas volumes (which would increase
NO<INF>X</INF> and GHG emissions, low inlet NO<INF>X</INF>
concentrations (leading to low removal efficiency and high ammonia
slip), and catalyst fouling concerns from particulates in BFG. SNCR is
also technically infeasible because the furnace exhaust temperatures
are far below the 1600-2100 [deg]F required for effective operation and
reheating would generate additional NO<INF>X</INF> emissions.
LNBs cannot be implemented for the cast house because it relies on
pilot flames instead of burners for the flare. Ohio determined that
LNBs are not economically reasonable because the stoves are already
meeting a NO<INF>X</INF> limit of 0.06 lb/MMBtu, which is similar to
emissions limits achieved by LNBs.
Ohio determined that RACT for this facility includes continued use
of low-NO<INF>X</INF> BFG for the cast house, flare, and stoves. Also,
Ohio determined that RACT includes minimizing NO<INF>X</INF> emissions
from the cast house and flare through proper operation and maintenance
in accordance with manufacturer specifications. For the blast furnace
stoves, RACT is defined as meeting a site-specific NO<INF>X</INF> limit
of 0.06 lb/MMBtu. The EPA proposes to approve Ohio's RACT determination
that these controls implement RACT.
[[Page 18353]]
E. Basic Oxygen Furnaces
Cleveland-Cliffs operates two basic oxygen furnace (BOF) systems: a
full-combustion system (No. 2 BOF, P925/P926) and a suppressed-
combustion system (No. 1 BOF, P905/P906). Because BOF vessels do not
use burners, LNBs are not technically feasible control options.
SCR and SNCR are also technically infeasible for BOFs. Gas
temperatures within the primary hoods vary throughout the batch blow
cycle, preventing the consistent temperature and residence time
required for either technology to operate effectively. In addition,
high particulate levels would quickly foul and poison catalysts.
Because no technically feasible control options are available to
meet RACT, Ohio established additional requirements for the BOFs,
including installing, maintaining, and operating each system in
accordance with manufacturer specifications and good operating
practices to minimize NO<INF>X</INF> emissions. The EPA proposes to
approve Ohio's determination that these controls implement RACT.
F. Ladle Preheaters
Steel shops use ladle preheaters to dry or cure refractory
materials. Available NO<INF>X</INF> control technologies for ladle
preheaters include SCR, SNCR, and LNBs. Because emissions from the
preheaters are fugitive and released directly into the melt shop
without a stack, post-combustion controls such as SCR and SNCR are
technically infeasible.
The preheaters already use inherently low-NO<INF>X</INF> burners.
Cleveland-Cliffs evaluated newer LNB designs but found them technically
infeasible for these preheaters due to the inability to maintain a
tight seal between the burner and ladle lip. The equipment is designed
to allow intentional air leakage to avoid suffocating the furnace, and
this air flow cannot be eliminated. As a result, operators cannot
control the combustion zone conditions needed to achieve or verify the
performance of newer LNBs, making additional NO<INF>X</INF> reductions
unlikely.
Therefore, Ohio determined that RACT includes continued use of the
existing inherently low-NO<INF>X</INF> burners for the ladle
preheaters. Also, RACT consists of continued compliance with the site-
specific NO<INF>X</INF> limit of 0.10 lb/MMBtu. Ohio's due diligence
review of control options for ladle preheaters at similar sources in
the RBLC supports this limit, as it is consistent with the most recent
BACT determination for comparable units. The EPA proposes to approve
Ohio's RACT determination that these controls implement RACT.
Ohio included the Cleveland-Cliffs Cleveland Works NO<INF>X</INF>
RACT requirements in construction permit number P0138036 and is
requesting that the EPA incorporate these provisions of the permit into
the SIP. In sum, the EPA is proposing to approve Ohio's RACT
determination for Cleveland Works with respect to NO<INF>X</INF>
emissions as adequately implementing RACT, and proposes to incorporate
by reference the above RACT requirements from permit number P0138036
(Effective Date: November 13, 2025), specifically sections C.1.b)1. j.,
C.1.b)1. k., C.1.b)2.h, C.1.d) 6., and C.1.d) 7., C.1.e)6., and
C.1.f)1.g. The EPA also proposes to incorporate by reference the above
RACT requirements from permit number P0138136 (Effective Date: November
13, 2025), specifically sections C.5.b)1.e.,C.5.b)1.f.,
5.b)2.d.,C.5.d)5., C.5.e)5., C.5.e)6., C.5.f)1.e., C.6.b)1.e,
C.6.b)1.f., C.6.b)2.d, C.6.f)1.b, C.7.b)1.i, C.7.b)1.j., C.7.b)2.f.,
C.7.d)6., C.7.d)7., C.7.e)7., C.7.f)1.e., C.8.b)1.f., C.8.b)1.g.,
C.8.b)2.e., C.8.d)3., C.8.e)5., C.8.f)1.d., C.9.b)1.e., C.9.b)1.f.,
C.9.b)2.f., C.9.d)3., C.9.e)4., and C.9.f)1.e. Additionally, the EPA
proposes to incorporate by reference the above RACT requirements from
permit number P0138521 (Effective Date: November 13, 2025),
specifically sections C.1.b)1.e., C.1.b)1.f., C.1.b)2.c., and
C.1.f)1.a.
VIII. Cleveland-Cliffs Cleveland Works--VOC RACT
Cleveland-Cliffs Cleveland Works LLC is also a major non-CTG VOC
source, with potential emissions exceeding 100 tpy, and is therefore
subject to site-specific VOC RACT under OAC 3745-21-11. Ohio submitted
this VOC RACT determination to the EPA on November 20, 2025. VOC
emissions at the facility originate from the boilers, reheat furnaces,
blast furnaces, BOF operations, and the tandem mill. The facility
operates under title V Permit No. P0129660 (effective March 9, 2021).
A. Tandem Mill (P107)
The tandem mill is a rolling mill consisting of multiple closely
spaced stands in a continuous line that emit VOCs from emulsified,
water-based rolling oils that form mist during operation. The unit is
equipped with a chevron-style oil demister that provides VOC reduction.
Cleveland-Cliffs evaluated multiple VOC control options:
<bullet> Thermal incineration: This is technically infeasible
because the 90 [deg]F exhaust temperature is significantly below the
1,300 [deg]F required, and reheating the high-moisture, low-VOC stream
would require excessive fuel, increasing both NO<INF>X</INF> and VOC
emissions.
<bullet> Catalytic incineration: This is technically infeasible due
to insufficient exhaust temperature (90 [deg]F vs. the 850-1,100 [deg]F
required), variable VOC concentrations, and risk of catalyst poisoning.
<bullet> Carbon adsorption: This is technically infeasible because
the exhaust stream would rapidly foul the carbon bed, making
regeneration or replacement impractical.
<bullet> Lower-VOC materials: This is technically infeasible due to
operational needs, steel quality specifications, and customer
requirements. Only the mill threading compound has a potential lower-
VOC substitute, but its use could destabilize the rolling oil and
compromise product quality.
The tandem mill's existing oil demister removes visible and
entrained oil vapor, moisture, and VOC mist. The facility is required
to maintain the mill and mist eliminator consistent with good
engineering practices. The tandem mill is also subject to a 12-month
rolling VOC limit of 138.91 tpy under Ohio's BAT program.
Because the alternative control technologies identified above are
technically infeasible, Ohio determined that RACT for the tandem mill
consists of continued operation of the oil demister using good
engineering practices, along with compliance with the BAT limit. The
EPA proposes to approve Ohio's assessment that these controls
constitute RACT.
Ohio also evaluated appropriate VOC content limits for oils used at
the tandem mill and adopted limits consistent with those applied at
Cleveland-Cliffs' Middletown Works facility. Ohio determined that the
following VOC content limits constitute RACT:
<bullet> Rolling Oil: <= 4.6 lb VOC/gal (excluding water and exempt
solvents)
<bullet> Rust Preventive Oil: <= 3.3 lb VOC/gal
<bullet> Anti-Galling Material: <= 1.2 lb VOC/gal
<bullet> Pre-Lube Oil: <= 0.8 lb VOC/gal
VOC content must be determined using the test methods in OAC 3745-
21-10 or, alternatively, ASTM E1868-10 at actual operating temperature.
The EPA proposes to approve Ohio's RACT determination that these
controls are RACT.
[[Page 18354]]
B. Gas Combustion Sources (Excluding Blast Furnaces)
This facility operates various combustion units including boilers,
reheat furnaces, annealing furnaces, and BOF vessels. Each unit's
actual emissions range from 0.1 to 6.6 tpy of VOCs, and add-on controls
are not economically reasonable. In addition, a review of the EPA's
RBLC database for comparable combustion sources installed within the
past five years shows that VOC BACT consists of good combustion and
operating practices.
Because the alternative control technologies for these units are
not economically reasonable, Ohio determined that RACT for these
sources consists of operating the units in accordance with manufacturer
specifications and good engineering practices. The EPA proposes to
approve Ohio's RACT determination that these controls implement RACT.
C. Blast Furnaces (P903 and P904)
Cleveland-Cliffs evaluated four potential VOC control technologies
for the combined blast furnace exhaust:
<bullet> Thermal and catalytic incineration: These are not
economically reasonable due to highly dilute VOC concentrations,
requiring substantial supplemental fuel. Cost-effectiveness ranges from
$99,676 to $134,286 per ton of VOC removed.
<bullet> Carbon adsorption: This is technically infeasible because
the exhaust temperature (500 [deg]F) exceeds operating limits for
carbon beds (<130 [deg]F), the stream is too dilute and moisture-laden,
and fire risks are significant.
<bullet> Scrubbing (absorption): This is technically infeasible
because meaningful VOC removal is not achievable at such low
concentrations without impractically large equipment, and scrubbers
typically must be paired with controls (carbon adsorption or
incineration) that are themselves infeasible.
<bullet> Condensation: This is technically infeasible because VOC
concentrations are far below levels where condensation would be
effective, and the required temperatures would cause moisture to freeze
and plug the system.
Because the alternative VOC technologies identified above are
either technically infeasible or economically unreasonable for the
blast furnace exhaust, Ohio determined that RACT consists of operating
the blast furnaces in accordance with manufacturer specifications and
good engineering practices to minimize emissions. The EPA is proposing
to approve Ohio's RACT determination that these controls constitute
RACT.
In sum, the EPA is proposing to approve Ohio's RACT determination
for Cleveland Works with respect to VOC emissions as adequately
implementing RACT and proposes to incorporate by reference the above
RACT requirements from permit number P0138035 (Effective Date: November
13, 2025), specifically sections C.1.b)1.e, C.1.b)2.a, C.1.d)2,
C.1.d)3, C.1.d)4, C.1.e)2, C.1.e)3, C.1.e)5, C.1.f)1.d, C.1.f)1.f,
C.1.f)2. The EPA also proposes to incorporate by reference the above
RACT requirements from permit number P0138036 (Effective Date: November
13, 2025), specifically sections C.1.b)1.i, C.1.b)2.g, C.1.d)6,
C.1.e)6.a. Finally, the EPA proposes to incorporate by reference the
above RACT requirements from permit number P0138136 (Effective Date:
November 13, 2025), specifically sections B.11, C.1.b)1.g, C.1.d)7,
C.1.e)5, C.2.b)1.g, C.2.d)9, C.2.e)6, C.3.b)1.e, C.3.d)4, C.3.e)4,
C.4.b)1.f, C.4.d)9, C.4.e)6, C.5.b)1.d, C.5.d)4, C.5.e)4, C.6.b)1.d,
C.6.d)3, C.6.e)4, C.7.b)1.h,C.7.d)5, C.7.e)6, C.8.b)1.e, C.8.d)2, and
C.8.e)4.
IX. What action is the EPA taking?
The EPA is proposing to approve the following as RACT in the
Cleveland Moderate nonattainment area with respect to the 2015 ozone
NAAQS:
<bullet> Lubrizol: continued compliance with site-specific RACT
under OAC 3745-21-09(LL) for all process reactor vents; use of
submerged filling and venting to a thermal oxidizer achieving greater
than 98 percent VOC control efficiency for the drum/tote filling
operations; and implementation of existing controls, emission limits,
and work practices for the loading racks as detailed in the permit
provisions described above.
<bullet> Henkel: continued current operational practices of
utilizing low-VOC materials and the use of condenser systems to reduce
VOC emissions by 85 percent, as detailed in the permit provisions
described above.
<bullet> Cleveland-Cliffs Cleveland Works
[cir] NO<INF>X</INF> RACT:
[ssquf] Reheat Furnaces (P046-P048): Requirement to submit updated
NO<INF>X</INF> RACT study per 3745-110-03(J) if NO<INF>X</INF>
emissions exceed 348.3 tpy per furnace on a 12-month rolling average.
[ssquf] Batch annealing Furnaces (P049 and P050): Continued
operation of existing LNBs and compliance with existing NO<INF>X</INF>
limit of 0.10 lb/MMBtu.
[ssquf] HDGL Annealing Furnace (Unit P071): Continued use of the
existing LNBs and compliance with the 0.23 lb/MMBtu NO<INF>X</INF>
limit.
[ssquf] Blast Furnaces (P903 and P904): Continued use of low-
NO<INF>X</INF> BFG; Casthouse and Flare- install, maintain, and operate
the source in accordance with manufacturer specifications and with good
operating practices for the control of NO<INF>X</INF> emissions; Blast
furnace stoves- Continued compliance with existing NO<INF>X</INF> limit
of 0.06 lb/MMBtu.
[ssquf] Basic Oxygen Furnaces and Ladle Preheaters (P905/P906 and
P925/P926): BOFs--install, maintain, and operate the source in
accordance with the manufacturer's specifications and with good
operating practices for the control of NO<INF>X</INF> emissions; Ladle
Preheaters- Continued use of the existing inherently low-NO<INF>X</INF>
burners and continued compliance of the site-specific NO<INF>X</INF>
limit of 0.10 lb/MMBtu.
[cir] VOC RACT:
[ssquf] Combustion Units (B001-B007, B046-B050, P903-P906): Operate
the source in accordance with the manufacturer's specifications and
with good operating practices for the control of VOC emissions.
[ssquf] Tandem Mill (P107): Continued operation of chevron-style
oil demister in accordance with good engineering practices; Compliance
with existing VOC BAT limit of 138.91 tons per rolling 12-month period;
Compliance with proposed VOC content limits for rolling oils described
in more detail in the preamble above.
X. Incorporation by Reference
In this rule, the EPA is proposing to include in a final EPA rule
regulatory text that includes incorporation by reference. In accordance
with requirements of 1 CFR 51.5, the EPA is proposing to incorporate by
reference Ohio rule 3745-21-09(LL), and the permit provisions discussed
in the preamble. The EPA has made, and will continue to make, these
documents generally available through <a href="http://www.regulations.gov">www.regulations.gov</a> and at the
EPA Region 5 Office (please contact the person identified in the FOR
FURTHER INFORMATION CONTACT section of this preamble for more
information).
XI. Statutory and Executive Order Reviews
Under the CAA, the Administrator is required to approve a SIP
submission that complies with the provisions of the CAA and applicable
Federal regulations. 42 U.S.C. 7410(k); 40 CFR 52.02(a). Thus, in
reviewing SIP submissions, the EPA's role is to approve State choices,
provided that they meet the criteria of the CAA. Accordingly, this
action merely approves State law as meeting Federal requirements and
does not impose additional requirements beyond
[[Page 18355]]
those imposed by State law. For that reason, this action:
<bullet> Is not a significant regulatory action subject to review
by the Office of Management and Budget under Executive Order 12866 (58
FR 51735, October 4, 1993);
<bullet> Is not subject to Executive Order 14192 (90 FR 9065,
February 6, 2025) because SIP actions are exempt from review under
Executive Order 12866;
<bullet> Does not impose an information collection burden under the
provisions of the Paperwork Reduction Act (44 U.S.C. 3501 et seq.);
<bullet> Is certified as not having a significant economic impact
on a substantial number of small entities under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.);
<bullet> Does not contain any unfunded mandate or significantly or
uniquely affect small governments, as described in the Unfunded
Mandates Reform Act of 1995 (Pub. L. 104-4);
<bullet> Does not have federalism implications as specified in
Executive Order 13132 (64 FR 43255, August 10, 1999);
<bullet> Is not subject to Executive Order 13045 (62 FR 19885,
April 23, 1997) because it approves a State program;
<bullet> Is not a significant regulatory action subject to
Executive Order 13211 (66 FR 28355, May 22, 2001); and
<bullet> Is not subject to requirements of section 12(d) of the
National Technology Transfer and Advancement Act of 1995 (15 U.S.C. 272
note) because application of those requirements would be inconsistent
with the CAA.
In addition, the SIP is not approved to apply on any Indian
reservation land or in any other area where the EPA or an Indian Tribe
has demonstrated that a Tribe has jurisdiction. In those areas of
Indian country, the rulemaking does not have Tribal implications and
will not impose substantial direct costs on Tribal governments or
preempt Tribal law as specified by Executive Order 13175 (65 FR 67249,
November 9, 2000).
List of Subjects in 40 CFR Part 52
Environmental protection, Air pollution control, Incorporation by
reference, Intergovernmental relations, Nitrogen dioxide, Ozone,
Reporting and recordkeeping requirements, Volatile organic compounds.
Dated: March 27, 2026.
Cheryl Newton,
Acting Regional Administrator, Region 5.
[FR Doc. 2026-06940 Filed 4-9-26; 8:45 am]
BILLING CODE 6560-50-P
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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.